Yesterday, the Multistate Tax Commission (MTC) held its annual meeting in Spokane, Washington. The meeting is the annual event where full MTC member states approve model laws in their final version. The approved versions are...more

Yesterday, the Multistate Tax Commission (MTC) held meetings of its Litigation, Uniformity, and Strategic Planning Steering Committees. The meetings were generally dominated by discussions of evolving apportionment issues,...more

EUROPEAN UNION RE-LAUNCHES FORMULARY APPORTIONMENT: KEY POINTS ABOUT THE CCCTB
The European Commission has recently released a Communication to the EU Parliament calling for a re-launch of its proposal from 2011...more

The Georgia law regarding apportionment of liability in tort cases became more clear this month with the Georgia Supreme Court’s decision in Zaldivar v. Prickett, et al. Before the Court was the question of whether a...more

Addressing the issue of damages for trade dress and design patents, the U.S. Court of Appeals for the Federal Circuit upheld the bulk of Apple’s roughly $930 million damages award, noting that there is no apportionment...more

This is the second of two articles guiding taxpayers through the next 24 months of state taxation’s turbulent waters. In this article, we address three additional significant trends.
Corporate Income Taxation: Heat and...more

In a victory for potentially responsible parties at multiparty contamination sites, a federal district court in U.S. v. NCR Corp., No. 10-C-910 (E.D. Wis. May 15, 2015), held a PRP established that environmental harm at a...more

An earlier Tax Alert discussed the possibility that North Carolina would adopt the single sales factor method of apportioning the business income of multi-state corporations. During the current legislative session, single...more

The highly publicized Apple v. Samsung litigation saga began in April 2011 when Samsung alleged various infringements of patents and trade dress related to Apple’s iPhone. A jury awarded more than $1 billion in damages. In a...more

Action Item: On March 15, 2015, the United States District Court for the Eastern District of Wisconsin in United States v. NCR Corp., No. 10-C-910 (E.D. Wis. May 15, 2015), held that a potentially responsible party (“PRP”) at...more

Although it has taken a surprisingly long time, the holding in Burlington Northern which greatly lowered the standard for apportionment in Superfund cases is finally being embraced by lower courts. Last fall I blogged about...more

Welcome to Real News! I’m pleased to introduce to you DLA Piper’s quarterly guide to key developments in English and Welsh real estate law. In this quarter’s edition:
- Mark Beardwood looks at service charge...more

Trial court may select the method of accounting for prior settlement in allocating response costs among liable parties, but claims to recover settlement payments are limited to costs consistent with the National Contingency...more

A recent Western Australian Court of Appeal case demonstrates the circumstances in which a court will join a prospective defendant in an apportionable claim.
In Hart v JGC Accounting & Financial Services Pty Ltd...more

For years, both the New York State Department of Taxation and Finance (the “Department”) and the New York City Department of Finance have aggressively sought to classify receipts generated by electronic or online service...more

Case Updates -
California Supreme Court Accepts Review of Documentary Transfer Tax Case In our last quarterly update, we reported on a controversial opinion recently published by a California Court of Appeal. In 926...more

As we reported on Friday, the Massachusetts Department of Revenue has promulgated its final regulations governing the apportionment of income (830 CMR 63.38.1). The regulations implement legislation that mandates...more

Bradley Arant Boult Cummings LLP’s State and Local Tax Team would like to share our year-end review—revisiting some interesting Tennessee tax developments for 2014 and announcing our annual “Tennessee Tax Issue of the Year.”...more

The Pennsylvania Department of Revenue (the Department) recently finalized its Information Notice on sourcing of services for purposes of determining the appropriate net income and capital franchise tax apportionment factors....more

What is a Fair, Reasonable, and Non-Discriminatory (FRAND) royalty for a few patents essential to practicing a technical standard like WiFi and how should the jury in such a case be instructed on damages? The Federal Circuit...more

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